Posted January 27, 2023
At the beginning of the pandemic, CMS implemented emergency waivers and other regulatory measures to enable flexibility for providers to continue to provide patient care. Those waivers remain in place pending further notice. One of the waivers allows home health agencies to provide more services using telecommunications technology as long as it is part of the patient’s plan of care and does not replace necessary in-person visits as ordered on the POC.
Telehealth’s New G-Codes
Currently, telehealth visits are not considered a home visit for the purposes of payment. However, to support the effort to gain reimbursement for telehealth services, agencies must begin reporting telehealth encounters utilizing the new G-codes. Collecting data on telecommunications will also provide valuable information regarding the characteristics of patients utilizing remote services to identify the types of social determinants that most benefit from these services.
The 3 new G-codes for telehealth will capture this data:
- G0320: Home health services furnished using synchronous telemedicine rendered via a real-time two-way audio and video telecommunications system
- G0321: Home health services furnished using synchronous telemedicine rendered via telephone or other real-time interactive audio-only telecommunications system
- G0322: The collection of physiologic data digitally stored and/or transmitted by the patient to the home health agency (for example, remote patient monitoring)
New G-code reporting requirements become mandatory on July 1, 2023. Until then, agencies have the option to voluntarily report these codes starting January 1, 2023.
Telehealth services should never replace home visits and the use of any telecommunications must be in the patient’s plan of care. But, in some instances, they may be the best or only avenue of communicating with the patient or their caregiver to obtain critical data.
Unplanned or Unexpected Discharge
In rare situations, clinicians may encounter an unplanned or unexpected discharge to end a home care situation where no in-home visit can be made. This could be for a variety of reasons including, but not limited to, the last qualified clinician who saw the patient is not available and no other qualifying clinician visits were made; patient non-compliance such as refusing further home visits; patient moves to another geographical location; or, the clinician is simply unable to find or reach the patient.
If all other steps in Category 2 Q15.3.6 Static Q&A have been exhausted to resolve this situation, then a telehealth encounter may yield the best results in obtaining accurate OASIS data. CMS Quarterly OASIS Q&A October 2020, Question 2 or CMS Quarterly OASIS Q&A July 2020, Question 4 provide guidance on how to use telehealth encounters with unplanned discharges.
A question was also submitted by Corridor to the Home Health Quality Questions to reaffirm this guidance and to clarify how it can be used to complete the OASIS-E assessment. Here is the CMS response:
Based on the CMS Interim Final Rule [CMS-5531-IFC] announced on April 30, 2020, HHAs have the flexibility, in addition to remote patient monitoring, to use various types of technology.
As per Home Health Agencies: CMS Flexibilities to Fight COVID-19
Telecommunications technology can include, for example: remote patient monitoring; telephone calls (audio only and TTY); and 2-way audio-video technology that allows for real-time interaction between the clinician and patient. However, only in-person visits can be reported on the home health claim.
Providers are expected to determine if the patient’s needs and the requirements of the Conditions of Participation can be met using telehealth encounter(s). Providers will also have to consider the technical capabilities of the agency and of the patient using telehealth encounter(s).
Therefore, when the telehealth encounter is used to deliver care, the telehealth encounter reflects the agency’s determination that the patient’s needs related to completion of the Discharge Comprehensive Assessment including OASIS may be completed using audio-only telecommunications technology.
Guidance effective during the current PHE allows for the discharge comprehensive assessment with OASIS to be completed by either the last qualified clinician to perform an in-person visit or the last qualified clinician to perform a telehealth encounter. In either case, the discharge comprehensive assessment documentation would be based on information from the assessing clinician’s last visit/encounter. To complete the OASIS items collected at discharge, the assessing clinician may collaborate with other agency staff, using information documented from patient visits/encounters that occurred in the last 5 days that the patient received care from the agency prior to discharge. The “last 5 days that the patient received care from the agency” is defined as the date of the last patient visit or encounter, plus the four preceding calendar days. Regulation requires that the discharge assessment must be completed within two calendar days of the actual discharge date or within two calendar days of learning of the need to discharge in the case of an unplanned or unexpected discharge.
The Temporary Guidance: COVID-19 Public Health Emergency (PHE) is in effect, with a retroactive effective date of March 1, 2020, through the end of the emergency declaration.
Stay Tuned for Updates on the Public Health Emergency Waivers
On January 11, 2023, the Department of Health and Human Services (HHS) extended the COVID-19 public health emergency (PHE) for another 90 days. The extended PHE will last at least until April 11, 2023. HHS has repeatedly stated that it would provide 60 days’ notice before ending the PHE to give home health providers time to prepare for changes. At this point, home health providers expect to know in early February if there are plans to end the public health emergency in April. Corridor will provide updates as CMS makes decisions about the PHE extension.
Learn More
There is always more to know when it comes to CMS rules and regulations! Of course, you can reach out to us at Corridor for guidance regarding ongoing changes. In the meantime, here is an additional link with reference materials from CMS regarding telehealth.
Resources: https://www.cms.gov/files/document/mm12805-telehealth-home-health-services-new-g-codes.pdf
About Corridor
For over 30 years, Corridor has partnered with home health and hospice providers, delivering powerful solutions to support the unique challenges of caring for patients in the home. Our team of operations executives, clinicians, and nationally renowned industry experts have run provider organizations and resolved the same challenges you face.
To receive the most important industry updates, insights and news impacting home health and hospice, please make sure to sign up for our weekly newsletter.
